An ongoing discussion of machine guarding topics, including solutions assessments, regulatory compliance, gap analysis, operating efficiencies and cost savings, as well as all relevant safety standards, such as those from NFPA, ANSI, RIA, IEC, ISO and OSHA. About J.B. Titus.
Machine Safety: Without an injury, OSHA issues citations for more than $1 million
January 23, 2012
Whoa, OSHA issues fines for $1,013,000. following a complaint filed by a worker. OSHA investigated the manufacturer and discovered 13 Serious and 17 Willful violations of Regulations. Was this Company just waiting to be caught in violation or were these violations a result of their safety culture. You decide!
The below article is one of several articles in this week’s OSHA QuickTakes newsletter. OSHA’s citations were issued on Dec. 28, 2011, and all abations are to be completed by Jan. 4 to Jan. 10, 2012. A summary of some of the citations include:
- No LOTO (lock out tag out) protection
- Defective brakes
- Lack of guarding
- No anti-repeat
- Lack of PPE
- Lack of fall protection
From a safety culture perspective is seems that this company has been incident free. Otherwise OSHA surely would have built some of their citations around those incidents. From a safety culture perspective would you begin to think that they might be one of those companies that think – “We’re Safe – We’ve Had No Machine Safety Accidents For A Long Time”? Or are they simply caught in some of the “myths of safety cultures” that I blogged about a few weeks ago? In my opinion, I can’t believe they we’re consciously waiting to be caught in violation.
In my opinion, you should register for receiving this newsletter from OSHA. It gives you a pulse of US industry and OSHA regarding safety behavior. The actual citations can be viewed at: www.osha.gov/ooc/citations/Piping-tech-prod-312928344-1228-11.pdf
Your comments or suggestion are always welcome so please let us know your thoughts. Submit your ideas, experiences, and challenges on this subject in the comments section below. Click on the following text if you don't see a comments box, then scroll down: Machine Safety – without an injury, OSHA issues citations for more than $1 million
Contact: www.jbtitus.com for “Solutions for Machine Safety”.
For more than 30 years, J.B. Titus has advised a wide range of clients on machine functional safety solutions, including Johnson + Johnson, Siemens, General Motors, Disney, Rockwell Automation, Bridgestone Firestone, and Samsung Heavy Industries. He holds a Bachelor of Business Administration degree from Oklahoma University in industrial management and an MBA from Case Western Reserve University in marketing and finance. He is a professional member of the American Society of Safety Engineers and is OSHA-certified in machine guarding. Titus is also TUV-certified as a Functional Safety Expert and serves on several American National Standards Institute, National Fire Protection Association, and National Electrical Manufacturers Association national safety and health standards committees. Reach him at jb(at)jbtitus.com and via www.jbtitus.com.
Wednesday, 25-01-12 11:34
It is impossible to judge whether there was an adequate safety culture and that the effectiveness of the culture should play a role in the fines. Past experience has shown that a lack of reported occurances can be due to just not reporting first aid incidents, employees perceived potential for retribution if injuries reported, etc. One would hope at this stage of OSHA implementation (40 yrs or so), that such punitive practices would not exist. One could rationalize that the lockout/tagout was sufficient if "minor" aspects were ignored, but some of the violations appear to be genuinely severe. A good safety culture cannot mitigate such things as faulty lifting equipment. In today's environment it staggers the imagination that someone would replace a roller, or similar work with NO energy isolation in place. I can't imagine that if the company's insurer were aware of these condition that the liability premiums alone would encourage implementation of basic measures. Maybe the Texas workman's comp laws facilitate this - I wouldn't know. In any case, one can only surmise that the company was living on "borrowed time", as were the employees. The employees were unquestionably exposed to hazards that could be and should be eliminated. It appears that the citations were justified, if not the fines.